On Sept. 13, 2020, CLINIC submitted a 45-page comment in opposition to DHS' Notice of Proposed Rule Making titled, "Collection and Use of Biometrics by U.S. Citizenship and Immigration Services," and published in the Federal Register on Sept. 11, 2020. If implemented, the proposed rule would have devastating ramifications on the lives of millions of immigrants and their U.S. citizen and lawful permanent resident relatives and would authorize invasive data collection, storage, and sharing. CLINIC urges DHS to withdraw the proposed rule in its entirety because the proposal: contains procedural deficiencies, would broaden the definition of "biometrics" and dangerously expand data collection, and would unjustifiably broaden the scope and duration of surveillance.